BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes, 1997
)
RECEWEL)
SEP 17 ‘-/ 19 f/j ‘97
Docket No. R97-1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORY
TO UNITED STATES POSTAL SERVICE
WITNESS JOE ALEXANDROVICH
(OCA/USPS-T5-4-42)
September 17, 1997
Pursuant to sections 25 and 26 of the Rules of Practice of the Postal Rate
Commission,
the Office of the Consumer Advocate hereby submits an interrogatory
request for production of documents.
Instructions included with OCA irrterrogatories
to the United States Postal Service dated July 16, 1997, are hereby incorporated
reference.
Respectfully submitted,
c4GiL&ti
GAIL WILLETTE
Director
Office of the Consumer Advocate
&%&El:*
Attorney
by
and
1-7
Docket No. R97-1
OCAfUSPST541.
2
Please refer to your W/P B-3, W/S 3.2.1., page 2, n. b. Please
state the location of the cited program.
If it is not already on file with the Commission,
please file it.
OGJUSPS-T5-42.
In response to OCA/USPS-T36-25.i.,
“significant changes in the costing methodology
witness Moell’er states that
make a direct comparison
of [the
letter/flat differential between Docket No. MC95-1 and Docket No. R97-I] difficult.”
OCA is experiencing
the same difficulty as the Postal Service’s own witness.
for OCA to make this determination
a.
For every cost component,
attribution methodology
i.
itself, please provide the following information:
list and describe all significant changes to cost
in this proceeding.
Provide a citation for each change listed to: testimony of a Postal Service
witness (by page and line), workpaper
(by worksheet,
page, column, and
row), and/or Library Reference (by page and line), as appropriate.
change has not been documented
the Commission,
ii.
In order
If the
in any information already on file with
then provide such documents and give all citations.
For each change listed in answer to part a., state whether it has the effect
of causing level of attribution for the component to increase, decrease, or
remain the same (choose one).
III.
If you are unable to provide the answers sought by this subpart, then
please redirect
the questions (or portions of questions) to witnesses who
can provide answers.
Docket No. R97-1
b.
3
For every cost component,
list and describe all significant changes to the
distribution key(s) used in this proceeding.
i.
For each, state whether the distribution key change involves substitution
of an entirely new distribution
key or a significant alteration to an existing
key.
ii.
Provide a citation for each change listed to: testimony of a Postal Sewice
witness (by page and line), workpaper (by worksheet,
palge, column, and
row), arid/or Library Reference (by page and line), as appropriate.
change has not been documented
the Commission,
III.
in any information
If the
already on tile with
then provide such documents and give all citations.
For each change listed in answer to pan b., give an additional listing of
how each subclass of mail is affected, i.e., for each subc:lass indicate
whether the new (or altered) distribution key causes the particular
subclass’ share of attributable
costs to increase, decrease, or remain the
same (choose one).
iv.
For each effect listed in subpart b.iii., provide a citation t’o: testimony of a
Postal Service witness (by page and line), workpaper
(by worksheet,
page, column, and row), and/or Library Reference (by page and line), as
appropriate.
If the effect has not been documented
in alny information
already on file with the Commission, then provide such documents
give all citations.
and
Docket No. R97-1
V.
4
If you are unable to provide the answers sought by this subpart, then
please redirect the questions (or portions of questions) tlo witnesses who
can provide answers.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon all
participants of record in this proceeding in accordance
practice.
Attorney
Washington, D.C. 20268-0001
September 17, 1997
with section 12 of the rules of